In a transactional legal malpractice case arising from the defendant lawyer’s advising plaintiff to enter into two marketing contracts that conflicted with each other, the plaintiff had to show only that the lawyer’s negligent advice was a substantial factor in causing her loss.  This she did at least sufficiently to overcome summary judgment by showing that she was considering not entering into one of the two contracts anyway and likely would not have done so if properly advised about the conflict.  Her damages from loss of the more profitable contract had to be offset under the special benefits doctrine by the money she received under the contract she said she would have not entered into, but even so she suffered a net loss in her expert’s opinion.  So summary judgment was improperly entered against plaintiff.